FEELING THE SQUEEZE? WHAT’S HAPPENING WITH PAY AT INVESTMENT BANKS AND ASSET MANAGERS
February 2015 (updated July 2015) by William Wright
> Average pay per employee at investment banks has fallen by a quarter since before the financial crisis. At asset management firms, average pay has increased by a fifth over the same period - and is catching up fast.
www.newfinancial.eu INTRODUCTION
Getting pay right
Pay in the financial markets is an emotive subject, but too much of the debate takes place in the dark.This report is an attempt to cut through some of the New Financial is a think tank and confusion, put some hard numbers on what has been happening to pay at forum that believes Europe needs investment banks and asset management firms over the past decade, and help bigger and better capital markets navigate some of the inconsistent and often misleading disclosure from the to help drive its recovery and industry. growth.
The question of pay and bonuses is not just about the numbers. Instead, it is an We think this presents a huge important barometer of the shifting balance in how the capital markets industry opportunity for the industry and thinks about itself in relation to its shareholders, to its clients, and to society. At its customers to embrace change New Financial, we believe that getting pay right is an essential part of the industry’s rehabilitation. and rethink how capital markets work. This report does not pretend to provide a definitive set of proposals to improve pay. Instead it is a flag in the ground that raises some of these questions: We are a social enterprise that launched in September 2014. We are self-financed and will seek • What is happening to pay at investment banks and how has that changed over time? financial support from institutions and individuals this year. • How does pay in the asset management industry compare? For more information on New Financial, contact us on: • How does pay fit in with and reflect the changing economics and regulatory environment of the industry? william.wright@newfinancial.eu This report focuses on two sectors: first, investment banks, rather than ‘banking’. This is because more than 80% of the pay and bonuses earned by those staff at +44 203 743 8269 banks who are designated as ‘high earners’ by European regulators goes to people who work in the corporate or investment bank divisions of their firm.
On average, staff at investment banks earn two to four times what their colleagues in the rest of the bank make. When people complain about pay at banks, what they really mean is pay at investment banks. Definitions
Second, we looked at asset management firms to test the consistency and When it comes to pay, definitions are comparability of disclosure, and to understand what is happening to pay in a important. This report uses sector that is moving up the regulatory agenda. ‘compensation cost per employee’ as an imperfect but constant proxy for The sample for the report was defined by the relatively small number of firms pay. This number divides ‘compensation that have comparable disclosure around pay. It includes 12 investment banks or and benefits’ or ‘staff costs’ in the corporate / investment banking divisions of larger groups, and 18 asset accounts by the average number of managers. All of the numbers are from publicly available sources and have been staff employed by the firm during the converted into US dollars at average annual exchange rates. year. It is not the same as ‘pay per employee’ because it includes other This report is a work in progress. Comparing firms across sectors is difficult, but costs such as social security, pensions we believe the report provides a directional guide to what is happening with and severance costs (actual pay would pay. We would welcome any feedback and suggestions on our approach. be about 15% to 20% lower). It also includes some elements of deferred Acknowledgements: bonuses from previous years but it’s I would like to thank Laurence Bax at New Financial for his diligent research and about as close to ‘pay per employee’ as data mining. Any errors are entirely my own. is possible under current disclosure.
www.newfinancial.eu 2 SUMMARY
> Pay at investment What is going on with pay at banks and asset managers? banks is taking up a shrinking portion of a !"#$%&'(&)#$*+*,&-&.#/&0#*&,1&2.&4566&714*&&& shrinking pot. At asset 9:6;4-20<:-$=:25$;48$46;>:?44$05$02245$60-07482$@$A-.$/0-12$)++*$5:$)+"*$BC+++$ management firms, it !&'$ !(#$ !!%$ !!!$ !!+$ is taking a constant !"#$ )(%$ )(*$ )&%$ )&%$ portion of a growing )*($ )#($ )'!$ one. )*&$ )**$ )#"$ )*#$ )"'$ )"*$ )+!$ "&&$ "'&$
)++*$ )++#$ )++'$ )++%$ )++&$ )++($ )+"+$ )+""$ )+")$ )+"!$ )+"*$ ,-.$/0-12$ 32245$60-07482$
• Pay at investment banks has fallen sharply. Pay per employee has dropped by more than a quarter since before the financial crisis and has fallen by more than 40% in real terms. But the rate of decline has slowed and last year average pay per employee increased slightly.
• Pay is still very high compared with the real world. Average compensation cost per employee at investment banks of $287,000 last year translates into actual pay of about $245,000 (€185,000 or £150,000), That’s six times median full-time earnings in the UK and just above the level of earnings needed to qualify for the top 1%, according to the ONS.
• The fall in pay marks a step change in the economics of the industry. Pay has fallen from roughly half of revenues at investment banks in the five years before the crisis to around 40% since. As a result, profits in 2013 were more than 50% higher than they otherwise might have been.
• Not everyone in the industry is feeling the pain: average pay per employee at asset management firms has increased by one fifth to $263,000 since before the crisis and has been rising steadily for the past decade. Pay in asset management used to be half the level of investment banks. Last year it was more than 90%.
• There is some evidence that pay is beginning to increase for the most senior bankers. Average pay for 6,000 ‘code staff’(senior management or risk takers) increased by 6% in 2013 from the year before to just under $2m (it fell by 2% for all staff across the industry)
• There is a huge concentration of income at the very top. On average, between one quarter and one third of the bonus pool at investment banks is paid out to just 1% of the staff.
• Asset managers and investment banks could significantly improve the division of reward between staff and shareholders. There is significant scope for further reductions in pay and staffing, and for sharing some of the efficiency and scale gains of the past decade with clients in the form of lower fees.
www.newfinancial.eu 3 THE DECLINE AND FALL OF BANKERS’ PAY
Feeling the pinch !"#$%&'(&)"#%&*+,-+,.&/001+,.$ 45-1.6-$7829-:3.;8:$7830$9-1$-29/8<--$.0$=:5$>.:?3$)++*$08$)+"*$@A+++$ It can be difficult to feel sorry for investment bankers, but in relative terms #++$ at least they have had a tough time over ,-./$0-123$ the past few years. Average pay per !&'$ !(#$ employee across the industry fell by 27% *++$ !!%$ !!!$ to about $287,000 between 2007 and !"#$ !!+$ )(%$ )(*$ )&%$ )&%$ 2014. In real terms, that’s a drop of more !++$ )*($ than 40% (see chart 2). )++$ In absolute terms, if you strip out estimated social security and other costs "++$ of around 15%, that translates into actual )++*$ )++#$ )++'$ )++%$ )++&$ )++($ )+"+$ )+""$ )+")$ )+"!$ )+"*$ pay of around $245,000 (or €185k or £150k). That means that average pay for the nearly 200,000 staff at the investment !"#$%&'(&)"*&+,-#.%&/0&%"*&.$+1+1&/2&-#3& banks in our sample automatically qualifies 345671$86$9:;<16=5>:6$9:=?=$<1@$1; '%#$ !"#$ The rate of decline has slowed in the past !%#$ few years and in 2014 we estimate that %#$ %#$ average pay increased slightly by 1% -.$"$ -.$*$ -.$,$ -.$+$ -.$($ /012$$ -.$)$ -.$'$ -.$!$ (mainly because of significant increases in &!%#$ average pay at two European investment &'%#$ &'!#$ &"%#$ &''#$ &''#$ banks in our sample). &'(#$ &)%#$ At some firms the fall in pay has been &+%#$ &)'#$ &)*#$ even steeper: average pay per employee &,%#$ &+"#$ at three investment banks in our sample has tumbled by more than 40% since 2007 (see chart 3), although at one large firm average pay has flatlined through the crisis. !"#$%&'(&)*+,"&#%&%"-&%*.$ 89./:5$;/$<.=$./>$?@/AB5B$C@D$E@>5$BF.G$.F$;/45BFH5/F$?./0B$'(!,$4B$'(!($#$ Leading by example !"#$ The most senior staff in the industry have %#$ taken their share of the pain. The data for so-called ‘code staff’ in Europe only goes 3456$$ 1-$!2$ 1-$,2$ 1-$'2$ back to 2010, but since then, their average 1-$%$2$ -./0$,$ -./0$)$ -./0$%$ -./0$*$$ &"#$ -./0$!!$ -./0$'2$$ -./0$7$2$ -./0$!($$ pay has fallen by one fifth (see chart 4) - -./0$!'2$$ a steeper fall than for more junior staff &'(#$ &'!#$ &')#$ &'*#$ &'+#$ over the same period. Banks are showing &,'#$ &,,#$ greater differentiation in pay: in 2013, pay &%(#$ &%'#$ for the most senior staff increased by 6% &%)#$ * Denotes a bank’s UK business only. &"(#$ to an average of just under $2m. Note: data for code staff pay only goes back to 2010 www.newfinancial.eu 4 A STEP CHANGE AT INVESTMENT BANKS Sharing the reward !"#$%&'(&)&*+#,,-$&*,./-&01&%"-&2.-& -./012/$3456/781947$0194$1:$;7./8:5/7:$<17=8$*++*$:4$*+"%$#$ Whatever else you may think about "'(#$ bankers’ pay and bonuses, there has been &+#$ !&#$ a step change in the economics of the !"#$ industry and in the division of reward %&#$ %'#$ %'#$ %'#$ !+#$ %'#$ between staff and shareholders since the %)#$ %"#$ financial crisis. )'#$ )(#$ )(#$ %+#$ In the years running up to the financial crisis, investment banks spent an average )+#$ of nearly half of their revenues on pay (chart 5). In a good example of misleading *+#$ financial jargon, this percentage is known *++*$ *++)$ *++%$ *++!$ *++&$ *++'$ *++($ *++,$ *+"+$ *+""$ *+"*$ *+")$ *+"%$ in the industry as the ‘compensation ratio’ (or the ‘comp ratio’). Average pre-crisis Average post-crisis 49% 41% Since the financial crisis, pay has fallen to an average of 40% of revenues. If you roll this shift out across the entire industry, it translates into a reduction in costs of !"#$%&'(&)*+*,*-.&%"/&012*30& around $25bn in 2013. That means pretax ./01230$1245$56$728$95$71092:$715;9<$29$=>/$?2>@<$,++,$95$,+%($#$ profits were around 50% higher than they otherwise would have been if pay had !"!#$ remained at the same relative levels as before the crisis. (("#$ Value for money ,"*#$ %&'#$ %''#$ %(%#$ %'%#$ %"&#$ %(*#$ %(-#$ %!-#$ The same trend is apparent when it %%+#$ comes to pay relative to pretax profits although it is less pronounced (see chart 6). The ratio of pay to profits is more volatile because profits are so variable. ,++,$ ,++"$ ,++($ ,++!$ ,++'$ ,++&$ ,++*$ ,++-$ ,+%+$ ,+%%$ ,+%,$ ,+%"$ ,+%($ When the industry has a bad year - such )*"#$ as in 2007, 2008 or 2011 - profits drop sharply but pay stays relatively constant (hence the ratio shoots up). This is not a new phenomenon so it is hard to pin on recent regulations. It suggests that variable pay stopped being genuinely variable some time ago. Notwithstanding recent regulations about deferred bonuses, there seems to be significant scope for increasing the variability of individual pay across the industry. www.newfinancial.eu 5 PAY IN ASSET MANAGEMENT A long-term game !"#$%&'(&)#$*+*,&-&.#/&0#*&,1&2.&4566&714*$ Not everyone is feeling the pain. While ,-./01234-1$5-26$/07$0./8-900$36$32206$.313:072$%''&$6-$%'!&$;<'''$ average pay at investment banks has been (''$ falling since the financial crisis, in the lower %)*$ %"($ profile world of asset management it has %&#$ %)!$ %&)$ %)'$ %&&$ been steadily rising. %!"$ %!&$ %'($ %''$ Since 2006 - the last full year before the !##$ 22% financial crisis - pay per employee at asset !"#$ management firms has increased by 22% !)'$ compared with a fall of 25% over the same period at investment banks (chart !''$ 7). We estimate that it increased slightly in %''&$ %'')$ %''"$ %''+$ %''#$ %''*$ %'!'$ %'!!$ %'!%$ %'!($ %'!&$ 2014 to $263,000, not far short of the $287,000 average at investment banks. Over the past decade, pay at asset !"#$%&'(&!)*+,-.&%"/&.#0&$ management firms has almost caught up -./0$1.23$045$4/06.744$83$82243$/898:452$82$8$#$.;$<9=$>89?2$,++)$3.$,+')$#$ with pay at investment banks. In 2004 '++#$ average compensation cost per employee *+#$ *,#$ was just over half that at investment banks &%#$ &!#$ &"#$ (chart 8).We estimate that it rose to 92% ()#$ (!#$ in 2014 and may soon overtake average %"#$ %'#$ pay at investment banks. !"#$ !%#$ !%#$ !+#$ Of course, asset managers and investment banks are not the same. They ,!#$ have different business models and there is a huge difference in scale: the 12 +#$ investment banks in our sample employed ,++)$ ,++!$ ,++%$ ,++($ ,++&$ ,++*$ ,+'+$ ,+''$ ,+',$ ,+'"$ ,+')$ 185,000 staff in 2013, while the 18 asset managers only employed 80,000 staff. BlackRock, the largest asset manager in the world, employs just one third as many !"#$%&'(&)*+*,-&./%&%"0&1%.$2& staff as Goldman Sachs. ./0$23:/;43$<=$2343>?35$$@ABCD$E$2343>?35$23:/;43$<=$7?9$@6BCD$/<$/553<$F/>/G325$*''&$<=$ *')&$#$ %'#$ '("'#$ It pays to be patient ./0$1$2345$#$ &%#$ '(+'#$ One reason for the increase in pay in 6345$1$789$#$ asset management is that it has remained '(%'#$ &'#$ !"#$ !"#$ constant relative to revenues over the !%#$ !%#$ '(&'#$ !%#$ !%#$ !&#$ !%#$ !&#$ !&#$ !&#$ past decade (chart 9).Revenues have also !%#$ remained fairly constant relative to assets '(!'#$ !'#$ under management, which have grown Pay relative to revenues Revenues relative to AuM '(*'#$ strongly. *%#$ '()'#$ *'#$ '(''#$ At investment banks, staff are taking a *''&$ *''%$ *''+$ *''"$ *'',$ *''-$ *')'$ *'))$ *')*$ *')!$ *')&$ shrinking portion of a shrinking pot. At asset managers, they are taking a constant portion of a growing one. www.newfinancial.eu 6 HOW PRODUCTIVE ARE BANKERS AND ASSET MANAGERS? Because you’re worth it !"#$%&'()&*+,&-$+./0123&#$3&4#563$78& ,-.=#10607809#-7>#/14<:9#/01#02/34.00#-:#?76#@-7A9#%""+#:4#%"!+## It is unlikely that many people working at 50@-90>#:4#!""#?7#%""+# investment banks will feel that they deserve to be paid less than before the !'"# crisis. And it is equally unlikely that people !%'# !!&# !%&# !%'# in asset management would think they !""# !"'# !"$# !")# !"(# don’t deserve the increases in pay that !""# )(# )*# )+# $'# )&# they have enjoyed over the past decade. ("# '"# One way of judging this is to compare the %'# change in pay per employee over the past decade with productivity in terms of "# revenue per employee and profits per %""+# %""'# %""*# %""$# %""(# %"")# %"!"# %"!!# %"!%# %"!&# %"!+# employee. ,-.#/01#02/34.00# 50607809#/01#02/34.00# ,10:-;#/14<:9#/01#02/34.00# *Note: in 2008, the average pretax profit per On the face of it, bankers look a little employee was a loss of $336,000 hard done by: average pay has fallen by !"#$%&''(&)*+&,$*-./012&#$2Ō%&4#5#62$37& 6% over the past decade but they generate more revenue and more profit ,-.?#10607809?#/14<:9#@#=8>#/01#02/34.00#-990:#2-7-A019#%""'#:4#%"!'## per employee than before (see chart 10). 50B-90C#:4#!""#D7#%""'# %("# %$(# At the same time, asset managers could argue that they more than deserve their %""# pay rise. While average pay per employee !+%# has increased by nearly 60% (chart 11), !))# !("# !((# !(*# revenues and profits per employee have !'&# !')# !'&# !'*# increased at a faster rate and asset under !%&# !%(# !%"# management per employee have !""# !!$# !""# increased twice as much. In other words, staff are a lot more productive than they ("# used to be. %""'# %""(# %"")# %""*# %""+# %""&# %"!"# %"!!# %"!%# %"!$# %"!'# ,-.#/01#02/34.00# 50607809#/01#02/34.00# Show me the money ,10:-;#/14<:9#/01#02/34.00# =8>#/01#02/34.00# A better indicator would be to adjust these metrics for inflation to measure any !"#$%&'()&*#$+,+-&%".,$&/..0& improvements in real terms. <=,1>/%?1%748@2AB0?5-%7/4%/C7D8-//%,5%,33/5%C,1,>/43%,1@%?10%E,1F3%?1%4/,D%5/4C3%$%% "GG*%58%"G&*% On that basis, staff at investment banks )*$% H%:332C/3%,0/4,>/%,112,D%?1I,B81%8J%"KL$% have become less productive over the past decade (see chart 12), suggesting there is significant scope for further cuts *"$% "($% in both staffing and pay - although their "'$% pay has fallen proportionately more. Staff at asset managers have become much more productive, suggesting that they +,-%% ./0/12/3% +4/5,6% +,-%% ./0/12/3% +4/5,6% :2;%% might be able to share more of the gains 748953%% 748953%% they have made in efficiency and scale !"#$% !&"$% !&&$% with their clients in the form of lower fees. &&&&&&&&&&1+2.3%4.+%&5#+/3& & &633.%&4#+#-.$3& (per employee) (per employee) www.newfinancial.eu 7 THE UNEVEN DISTRIBUTION OF BANKERS’ PAY We are the 1% !"#$%&'()&*+,-.#/0%12&3#+4,$&5%1/,& 01232142,$25$626+7$82,9:$3227$3+;<$62$=2<>$:6+?$&"(@$ When it comes to pay at investment banks, there is no such thing as ‘average’. Even though ‘average’ pay !"#$ across the industry is high enough to %&#$ automatically qualify for the 1%, at most banks pay is so heavily &'#$ &!#$ concentrated at the very top that it &&#$ could merit the attention of Thomas &"#$ Piketty. ((#$ At one investment bank in our sample, for example, the top 1,100 staff in the investment bank - just 4% )*$!$ *+,-$!$ *+,-$&$ *+,-$.$ *+,-$($ *+,-$("$$ *+,-$/$$ of the total - shared half of the total Number of staff (and % of total at firm) 1,093 1,295 503 530 543 342 330 bonus pool in 2013 (see chart 13). 4.1% 1.3% 1.1% 0.4% 0.9% 0.3% 0.1% At other banks the allocation of bonuses may be less extreme, but at group level, the top 1% of earners !"#$%&'()&*"+&%,$#--,&./�+$#1+2&& share one quarter to one third of A327CD:E$8,F:$G7H237E2G$.75$71$D:H201-2:1$>7:C0$D:$!)&#$IG)))$ the bonus pool between them. @A$B$ @A$'$$ &'()$&'*)$ =$J0K-7120$ Well above average These numbers make a mockery of ‘average’ pay. Using data from two European banks which provide an unusual level of disclosure, the %'"$ %#*$ average compensation cost per !"#$ !"%$ !#%$ !&"$ &'($ &(&$ employee in 2013 in their &&*$ &)($ investment bank divisions was $283,000 and $284,000 (see chart +,-.$/,01$ 675$.23$ 675$.23$/,82$675$.23$:,:; 675$.23$1,.$ 675$.23$ 14). .23$2-.4,522$ 2-.4,522$ 0179$$ /,82$0179$$ &<#=$ >,?,-$!<#=$ However, the top 4% of staff at one of the investment banks earned roughly 10 times the average pay for the remaining 96%. If we assume that the top third of staff at investment banks earn two thirds of total pay (which seems conservative), it means that the average pay for the bottom two thirds of staff at investment banks is around $110,000 (€83k or £70k), which is still high in relative terms, but much closer to most people’s frame of reference. www.newfinancial.eu 8 HOW FLEXIBLE IS PAY AT INVESTMENT BANKS? Capping the flow !"#$%&'()&*"#%&+,-./&0#12&& 5.67#78#2.9:.;<3#=7#>?3@#A.B#879#C7@3#D=.E#.=#;./0D#:/#(&%$# In the debate around pay, few things -#@3/7=3D#FG#;HD:/3DD#7/ For example, two banks which disclose enough data show that they would have to raise fixed pay for the code staff in their investment banks by about half to comply with the new rules (see chart 16). But this cost is only about 2% of the wage bill and just 1% of the total costs in each investment bank, and adds up to less than 1% of total group costs. If a bank struggles to absorb a 1% increase in fixed costs, it probably has deeper problems than the bonus cap. www.newfinancial.eu 9 GETTING THE RIGHT BALANCE Juggling act !"#$%&'()&*"+&,#-#./+&01&$+2#$3&& @;A$9212BC2<$A292$DE1ED2D$C>$47$EB12<7F2B7$G4BH<$4BD$4<<27$F4B4I29<$G27A22B$ The real measure of whether >45J$;7829$:;<7 www.newfinancial.eu 10 APPENDIX The distribution of pay at asset managers and investment banks This chart shows the wide range of pay per employee across the asset management and investment banking industry. While asset management firms dominate the lower end of the table, it is worth noting that how high pay per employee is at many asset managers compared with investment banks and with what one might expect. !"#$%&%'()*+,---% ,012341$567819:3;69$56:<$812$178=6>11$3<$3::1<$7393412:$39?$@901:<719<$A39B:$@9$*()%$CD((($ &(($ !"#$ +(($ !(($ %&'$ %&%$ %%($ %)*$ #"%$ #'!$ #'%$ #'*$ #&&$ #&+$ %(($ #!"$ #*'$ #*%$ #*($ *"+$ *'"$ *'&$ *&&$ #(($ *+#$ *!"$ *!'$ *!&$ *!!$ *##$ *#($ **"$ *)!$ *(*$ *(($ )+)$ )(($ ($ ./$%$ ./$+$ ./$&$ ./$!$ ./$*$ ./$)$ ./$#$ ./$'$ ,-$*$ ,-$'$ ./$))$ ,-$#$ ./$)*$ ,-$%$ ,-$!$ ,-$&$ ./$)($ ,01$./$ ,-$)$ ,-$"$ ,-$+$ ,-$)#$ ,-$)*$ ,-$)!$ ,01$,-$ ,-$))$ ,-$)&$ ,-$)($ ,-$)+$ ,-$)'$ Sample and methodology: Our sample included 18 asset management firms or asset management divisions of larger groups which have comparable disclosure on pay, and 12 investment banks or corporate / investment banking divisions of larger groups. We also analysed data on ‘code staff’ at 18 banks and investment banks. All of the numbers have come from public disclosures, and have been converted into USD at average annual exchange rates. We have used average headcount (reported or estimated) to calculate compensation cost per capita, and year end reported AuM, and all of the results are weighted. Banks (for code staff) Asset managers Investment banks Bank of America Merrill Lynch Aberdeen Asset Management Barclays (investment bank) Barclays Affiliated Managers Group Credit Suisse (investment bank) BNP Paribas Allianz Asset Management (Pimco + Deutsche Bank (corporate banking & AGI) securities) Citi Ashmore Evercore Commerzbank BlackRock Goldman Sachs (group) Credit Suisse Franklin Templeton Greenhill Deutsche Bank GAM Holding Jefferies Goldman Sachs Henderson JP Morgan (corp & investment bank) HSBC Invesco Morgan Stanley (Inst securities) JP Morgan JP Morgan Chase (AM division) RBS (markets division) Lloyds Julius Baer Rothschild (Paris Orleans) Morgan Stanley Jupiter UBS (investment bank) Nomura Man Investments RBS Morgan Stanley (AM division) Santander Schroders Societe Generale T. Rowe Price Standard Chartered UBS (AM division) UBS Unicredit (AM division) www.newfinancial.eu 11 FOR DISCUSSION... Getting pay right... Here are 10 suggestions and questions for discussion on how asset management firms and investment banks could improve the award and disclosure of pay: Disclosing pay: 1. An excellent place to start would be for the asset management and investment bank divisions of larger firms to disclose what they pay their staff (many of them don’t). Given the regulatory and political focus on pay - which is often more than half of all costs - the reluctance of many firms to disclose it does not encourage trust. 2. Attempts by different regulatory bodies in different countries to improve transparency have led instead to a confusing and inconsistent range of disclosure. What could the industry do to create a single, comparable template for pay disclosure? What is stopping the industry from adopting this approach? 3. Several firms such as Barclays have set a high bar in terms of voluntary disclosure on pay and bonuses. It publishes a detailed breakdown of fixed pay and bonuses in its investment bank. What is preventing other firms from following suit? 4. Disclosure around deferred bonuses is particularly patchy and inconsistent (the data is so poor that we have ignored it in this report). Given the political prominence of deferred bonuses, how can the industry improve disclosure in this area? 5. When it comes to pay disclosure, the distribution of pay is more important than detail on individuals. How can banks and asset managers use greater transparency to address the myth that all of their staff are paid millions of dollars a year? Awarding pay: 6. What role can pay and bonuses play in helping the industry develop more of a partnership culture? How can the allocation and structure of pay encourage employees to adopt a longer-term and collective approach with more personal risk? 7. What is the right amount of pay? To what extent does high pay reflect a genuinely competitive market for talent? Instead of focusing on pay, should customers, shareholders and regulators instead be focusing more on overall levels of revenue and fee structures off which pay is based? 8. The process of calculating and awarding pay can be surprisingly informal and discretionary. How could a process that allocates bonuses on clear financial metrics - say, a combination of group, divisional, desk and individual performance - as well as incorporating non-financial individual targets - improve pay? 9. Much of the regulatory pressure on pay and bonuses has focused on increasing the proportion of pay that has to be deferred and the length of time it is deferred for. How could the period over which pay is calculated be extended backwards (so that pay is not awarded on a calendar year, but perhaps instead on a rolling three or even five year basis)? 10. Every asset management firm and investment bank says they are committed to the best interests of their clients. How could pay in the industry be more closely aligned with client outcomes instead of being based on often blunt metrics such as revenue, growth and market share? www.newfinancial.eu 12